Money Laundering Enforcement Trends: Summer 2020
The U.S. Securities and Exchange Commission (SEC) stated in its Office of Compliance Inspections and Examinations 2020 Examination Priorities, that Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance remains a priority. There have been significant actions during the past six months by U.S. and foreign regulators against individuals and companies for money laundering activities.
Recent AML compliance and enforcement efforts have of course been impacted by the ongoing COVID-19 epidemic. Authorities such as the Financial Crimes Enforcement Network (FinCEN) have issued guidance related to COVID-19 (discussed further below). Also worth noting is the April 1, 2020 statement from the president of the Financial Action Task Force (FATF) regarding COVID-19 and measures to combat illicit financial activity, which encourages continued risk-guided flexibility in AML efforts. Specifically, according to the statement, "FATF encourages governments to work with financial institutions and other businesses to use the flexibility built into the FATF's risk-based approach to address the challenges posed by COVID-19 whilst remaining alert to new and emerging illicit finance risks. The FATF encourages the fullest use of responsible digital customer onboarding and delivery of digital financial services in light of social distancing measures." This is important to remember as companies seek to calibrate their AML efforts during this unprecedented time.
In this edition's Spotlight, we focus on the United Kingdom, where recent cases have brought Unexplained Wealth Orders into the news.
FinCEN has been active recently, issuing guidance on COVID-19, an advisory on jurisdictions with AML/CFT deficiencies, a renewed Geographic Testing Order, and public remarks regarding transparency and information-sharing.
FinCEN Issues Guidance Related to COVID-19
FinCEN has published two updates related to the COVID-19 pandemic. Overall, the guidance provides institutions with some relief related to the administrative aspects of AML regulatory compliance, but does not excuse failures to take required steps, and, indeed, puts institutions on notice of certain heightened money laundering risks associated with the COVID-19 pandemic.
On March 16, 2020, FinCEN advised financial institutions that are affected by COVID-19 to contact FinCEN and their functional regulators about any potential delays with filing BSA reports and encouraged financial institutions to remain vigilant. As part of its monitoring, FinCEN identified the following four trends in illicit behavior connected to COVID-19:
- Imposter scams, including attempts to solicit donations, steal personal data, or distribute malware by posing as governmental, international, and/or health agencies and organizations
- Investment scams, including attempts to lure targets to invest in products or services of publicly traded companies under the false pretense that such products or services can prevent, detect, or cure COVID-19
- Product scams, including the sale of products that make false claims related to COVID-19 and the fraudulent marketing of COVID-19-related supplies
- Insider trading related to COVID-19
In addition, FinCEN instructed financial institutions to review FinCEN's "Advisory to Financial Institutions Regarding Disaster-Related Fraud," published in October 2017, for descriptions of other relevant categories of behavior and for financial institutions to specify if the behavior is related to the COVID-19 pandemic when completing suspicious activity reports (SARs).
On April 3, 2020, FinCEN published a second release in which it provided further guidance and updates regarding five issues related to COVID-19:
- First, FinCEN advised that it "expects financial institutions to continue following a risk-based approach, and to diligently adhere to their BSA obligations," but that it "appreciates" that the COVID-19 pandemic "created challenges in meeting certain BSA obligations, including the timing requirements for certain BSA report filings" and that it will continue to coordinate with relevant stakeholders to "to ensure risk-based compliance with the BSA."
- Second, FinCEN addressed the collection of beneficial ownership information for existing customers as it relates to the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Paycheck Protection Program (PPP). FinCEN advised that for "eligible federally insured depository institutions and federally insured credit unions, PPP loans for existing customers will not require re-verification under applicable BSA requirements, unless otherwise indicated by the institution's risk-based approach to BSA compliance."
- Third, FinCEN noted that financial institutions and trade associations reported having difficulties with meeting certain BSA obligations, including the timing requirements for certain BSA report filings, and acknowledged that there may be "reasonable delays" in compliance. In addition, it suspended the implementation of FIN-2020-R001 (2020 Ruling) on Currency Transaction Report (CTR) filing obligations with respect to reporting transactions involving sole proprietorships and entities operating under a "doing business as" (DBAs) name until further notice. FinCEN clarified that financial institutions should report transactions involving sole proprietorships and DBAs under prior practice unless they already made the changes to adhere to FIN-2020-R001, in which case they may continue to report CTRs consistent with the 2020 Ruling.
- Fourth, FinCEN announced it created a "COVID-19-specific online contact mechanism, via a specific drop-down category, for financial institutions to communicate to FinCEN COVID-19-related concerns while adhering to their BSA obligations," including regarding delays in filing BSA reports as a result of COVID-19. FinCEN clarified that COVID-19-related communications are "strongly encouraged but not required."
- Fifth, FinCEN encouraged financial institutions to consider, and where appropriate, implement "innovative approaches" to meet BSA/AML compliance obligations and, consistent with its March 16, 2020 release, to remain "alert for malicious or fraudulent transactions similar to those that occur in the wake of natural disasters."
FinCEN Issues Advisory on FATF-Identified Jurisdictions with AML/CFT Deficiencies
On March 26, 2020, FinCEN issued an advisory to U.S. foreign institutions regarding classification of countries by the FATF. The FATF has identified 20 countries as AML/Combatting the Financing of Terrorism (CFT) deficient. FinCEN cautioned that these warning lists "may affect U.S. financial institutions' obligations and risk-based approaches with respect to relevant jurisdictions."
As of February 21, 2020, the FATF identified two "High-Risk Jurisdictions Subject to a Call for Action" (the Democratic People's Republic of Korea (DPRK) and Iran) and 18 "Jurisdictions under Increased Monitoring." FATF added the following countries to the list of Jurisdictions under Increased Monitoring: Albania, Barbados, Myanmar, Jamaica, Nicaragua, Mauritius, and Uganda. Trinidad and Tobago was removed from the list and the following countries remained on the list: The Bahamas, Botswana, Cambodia, Ghana, Iceland, Pakistan, Panama, Mongolia, Syria, Yemen, and Zimbabwe.
U.S. financial institutions are already prohibited from engaging in transactions or dealings with the DPRK and Iran and their financial institutions, including opening or maintaining correspondent accounts, per U.S. sanctions law and regulations, executive orders, and FinCEN regulations. With regard to FATF "Jurisdictions under Increased Monitoring," FinCEN reminds U.S. financial institutions to "consider the risks associated with the AML/CFT deficiencies" of these jurisdictions. It also reminds U.S. financial institutions subject to U.S. law setting forth requirements under U.S. AML programs, to include 31 U.S.C. § 5318(h) and 31 CFR §§ 1010.610(a) and 1010.210, to "comply with their due diligence obligations for Foreign Financial Institutions (FFI)." FinCEN also adds that money services businesses (MSBs) must comply with FinCEN Interpretive Release 2004-1, which sets forth an MSB AML Program, including policies, procedures, and controls.
FinCEN Renews Geographic Testing Orders to Real Estate
On May 8, 2020, FinCEN issued a Geographic Targeting Order requiring title insurance companies to obtain and report information about certain real estate transactions. Under the Order, title insurance companies must provide information for certain residential real property transactions that are $300,000 or more in specified metropolitan areas delineated in the Order. The metropolitan areas covered include several major cities, including New York, Los Angeles, San Francisco, and Miami. The Order is effective from May 10, 2020 through November 5, 2020 and also imposes record retention obligations. We covered a previous Geographic Testing Order here.
FinCEN Deputy Director Discusses Information Sharing
On February 6, 2020, FinCEN Deputy Director Jamal El-Hindi delivered remarks at the Securities Industry and Financial Markets Association's 20th AML and Financial Crimes Conference in New York, during which he discussed three overarching topics: (1) the evolution in AML compliance; (2) the value of BSA information; and (3) the current regulatory environment.
Much of El-Hindi's discussion compliance focused on the importance of transparency, including information-sharing pursuant to Section 314(b). El-Hindi acknowledged the challenges for the financial sector for achieving transparency, including the "complexity of the transactions and relationships" in the sector and that "the culture of any highly competitive industry may discourage sharing customer information for the purpose of anti-money laundering or other financial crime prevention, when it could result in potentially losing a customer to a competitor." Indeed, he noted that while "[d]epository institutions have a 40 percent participation rate in the Section 314(b) program... securities sector institutions have only a 14 percent participation rate." He encouraged relevant stakeholders "to work toward the sharing of more information with one another, either bilaterally or through associations under 314(b), to root out illicit activity."
In addition, El-Hindi emphasized the value of information provided under the BSA. He stated that law enforcement authorities and regulators query BSA filing data approximately 30,000 times per day to support "ongoing investigations, examinations, victim identification, analysis and network development, sanctions development, and U.S. national security activities, among many, many other uses." He also highlighted the deterrent value of the information.
Two recent actions against individuals are noteworthy – one represents the first guilty plea associated with the Panama Papers investigation and the other is the conviction, appeal, and sentencing of a former Alstom executive for activity in connection with Alstom's 2014 $772 million settlement with the U.S. Department of Justice (DOJ) to resolve Foreign Corrupt Practices Act (FCPA) allegations.
German Businessman is First to Plead Guilty in the U.S. in Panama Papers Investigation
German and Guatemalan dual-national Harald Joachim von der Goltz, a former resident of the U.S., pleaded guilty to several charges connected to evading U.S. income taxes and reporting requirements as a result of the investigation of the Panama Papers. The Panama Papers refer to the leak of financial records from Panama-based Mossack Fonseca, which were obtained by a German newspaper and exposed a network of offshore companies used to hold assets. He also pled guilty to money laundering and making false statements. Von der Goltz is the first known U.S. taxpayer to plead guilty to criminal charges in connection with the Panama Papers investigation. Von der Goltz is a former client of Mossack Fonseca. The U.S. government successfully extradited von der Goltz from the United Kingdom and alleged that von der Goltz, a former U.S. taxpayer, engaged Mossack Fonseca to create a series of sham foundation and shell companies in Panama and the British Virgin Islands to hide his ownership of bank accounts in overseas banks. According to the U.S. government, other defendants in the case (including Panamanian lawyer Ramses Owens, who previously worked at Mossack Fonseca) and Richard Gaffey, a partner at a U.S.-based accounting firm, aided von der Goltz in this scheme. Von der Goltz is scheduled to be sentenced in June.
Former Alstom SA Executive Sentenced on Money Laundering Charges
On March 6, 2020, Lawrence Hoskins, a British national employed by Alstom S.A.'s U.K. subsidiary, was sentenced to 15 months in prison and a $30,000 fine in connection with money laundering charges relating to a scheme to bribe Indonesian officials to secure a power contract. A jury convicted Hoskins in November 2019 of money laundering violations as well as FCPA violations and conspiracy to violate the FCPA.
On February 26, 2020, the U.S. District Court for the District of Connecticut upheld the money laundering charges while overturning the jury verdict against Hoskins on the FCPA counts. With respect to the money laundering charges, the court found that the jury was entitled to credit evidence submitted by DOJ that the transfer at issue from Maryland to Indonesia was one "single, continuing" transaction, although Hoskins had argued that the transaction involved two separate transfers. The court found, therefore, that Hoskins had not demonstrated that the evidence at trial was insufficient to support the jury's determination that the venue requirements of 18 U.S.C. § 1956, prohibiting the laundering of monetary instruments, had been satisfied.
The DOJ has appealed the court's ruling on the FCPA counts, where the court found that the evidence presented at trial was insufficient to support the jury's finding that Hoskins was an "agent" of a "domestic concern" and therefore subject to the FCPA.
As discussed in previous newsletters (see here), U.S. authorities continue to pair sanctions and money-laundering charges. Two recent settlements highlight this trend.
Industrial Bank of Korea settled AML and sanctions charges and agreed to pay $86 million. In April 2020, the Industrial Bank of Korea (IBK) and its New York subsidiary (IBKNY) settled allegations with the New York State Department of Financial Services (NYDFS) and the U.S. Attorney's Office for the Southern District of New York in connection with investigations into the bank's processing of over $1 billion in transactions violating U.S. sanctions against Iran. IBK entered into a Deferred Prosecution Agreement (DPA) with the U.S. Attorney's Office and a Consent Order with NYDFS. According to the U.S. Attorney's Office, from at least 2011 until 2014, IBK and IBKNY willfully failed to establish, implement, and maintain an adequate AML program at IBKNY. Specifically, "[d]espite requests and admonitions from regulators and IBKNY's own compliance officer […], IBK and IBKNY failed to provide the resources, staffing, and training necessary to maintain an adequate AML program by declining to take steps to implement an automated transaction review program or to provide the Compliance Officer with any support staff or assistance. This failure permitted, among other things, the processing through IBKNY and other U.S. financial institutions of approximately $1 billion in transactions on behalf of one or more IBK customers that violated [the International Emergency Economic Powers Act] IEEPA." IBK agreed to pay $51 million in forfeiture and a $35 million penalty to NYDFS.
Turkish state-owned Halkbank indicted on sanctions, bank fraud, and money laundering charges. In October 2019, the DOJ announced six economic sanctions, bank fraud, and money-laundering counts against Turkiye Halk Bankasi A.S. (Halkbank), a state-owned bank based in Turkey. As we reported in our inaugural issue, DOJ has previously brought similar charges against individual Halkbank executives, including former Deputy General Manager Mehmet Hakan Atilla, who was convicted in May 2018. The charges against Halkbank itself are arise out of the same alleged scheme to assist the Central Bank of Iran, the National Iranian Oil Company, and the National Iranian Gas Company in repatriating proceeds from international oil and gas sales, including through the purchase of gold in Dubai on behalf of the Government of Iran and the fabrication of transactions purporting to show imports of food and medicine to Iran (one of the few paths for payments into and out of Iran). Halkbank has not indicated any willingness to enter into any settlement with DOJ regarding the allegations and has refused to appear in U.S. court other than to seek dismissal of the charges.
U.S. enforcement officials continue to focus on cryptocurrency.
Alleged Cryptocurrency Compliance Failures Result in Consent Order for New York Bank
In January 2020, the U.S. Department of Treasury Office of the Comptroller of the Currency (OCC) issued a Consent Order against M.Y. Safra Bank, FSB (Safra), based in New York, New York. From November 2016 to February 2019, Safra began rolling out banking services for "digital asset customers," including digital currency ATM operators, crypto arbitrage trading accounts, blockchain developers and incubators, and traditional fiat currency MSB customers. According to the Consent Order, Safra failed to implement commensurate controls to address the increased BSA/AML risk that came with this expanded, higher-risk customer base. Based on this alleged failure, the OCC found that Safra had violated regulations requiring certain BSA monitoring procedures. Under the Consent Order, Safra is required to adopt certain compliance commitments, including the establishment of a Compliance Committee, development of a written program of internal controls and processes to ensure compliance with SAR filing requirements, development of a written program of internal controls for compliance with the BSA, development of a risk assessment that accounts for BSA/AML and Office of Foreign Assets Control (OFAC) risk.
Big Law Partner Convicted of Laundering Fraudulent Proceeds of OneCoin
In November 2019, former Locke Lord LLP partner Mark Scott was convicted of money laundering for helping to launder more than $400 million of proceeds from a pyramid scheme involving the purported cryptocurrency OneCoin. Konstantin Ignatov, the brother of "Cryptoqueen" Ruja Ignatova, pled guilty and testified on behalf of the government in Scott's trial, according to media reports.
According to the government, starting in 2016, Scott formed a series of fake private equity funds and disguised incoming transfers into those funds (totaling $400 million) as investments from wealthy European families when in fact the money was proceeds from the OneCoin fraud scheme. Scott also helped transfer the funds out of the fake private equity funds to Ignatova and others.
The DOJ has described OneCoin as a "massive pyramid fraud scheme." According to the government, contrary to the company's representations, the value of OneCoin is determined internally, not based on supply and demand, and coins are not mined using computer resources. The government has alleged that OneCoin was created in order to defraud investors.
DOJ Charges Two Chinese Nationals with Laundering $100 million in Hacked Cryptocurrency
In March 2020, DOJ unsealed an indictment against Tian Yinyin and Li Jiadong for laundering more than $100 million in stolen cryptocurrency following the hack of a cryptocurrency exchange.
According to the indictment, which was filed in federal court in Washington, DC, the unnamed virtual currency exchange was hacked in late 2018 and nearly $250 million worth of virtual currencies were stolen. Yinyin and Jiadong both had virtual currency accounts at unnamed currency exchanges and they used those accounts to exchange more than $100 million, most of which was traceable to the hack of the currency exchange.
In its press release, DOJ said that currency exchanges were made by Yinyin and Jiadong for the benefit of actors in North Korea. The civil forfeiture complaint names 113 virtual currency accounts used by Yinyin, Jiadong, and other unnamed co-conspirators. The forfeiture complaint seeks to recover the funds, some of which have already been seized.
As we reported in our previous edition of Money Laundering Enforcement Trends, the 5th Anti-Money Laundering Directive (5AMLD), which amended the 4th Anti-Money Laundering Directive, was published in the European Union (EU) Official Journal on June 19, 2018. EU Member States had until January 10, 2020 to apply 5AMLD to their national laws, making it applicable law across the EU. As we observed in November 2019, 5AMLD was generally seen as a demonstration of EU's increased efforts to combat money laundering and terrorist financing by, among other things, increasing the cooperation between EU member states' financial intelligence units, improving the checks on transactions involving high-risk non-EU countries, expanding the access to information on beneficial ownership, and improving the transparency in the ownership of companies and trusts.
Although 5AMLD introduced substantial improvements to the EU's ability to prevent the use of the financial system for money laundering and terrorist financing activities, it failed to address and/or clarify certain issues, including what should be considered a "money laundering offence." Enter the 6th Anti-Money Laundering Directive (6AMLD or the Directive), which, among other amendments, defines and explains the offense of money laundering and the consequences (i.e., penalties) for those committing it.
The following are several key changes in 6AMLD:
- 6AMLD defines "criminal activity" in Article 2, which states that offenses falling within 22 categories (Article 2(1)(a)-(v)) are considered to be criminal activity. EU Member States "should ensure that all offences that are punishable by a term of imprisonment as set out in this Directive are considered predicate offences for money laundering."
- Article 3 of the Directive defines "money laundering offense." According to that article, the following conduct, "when committed intentionally, is punishable as a criminal offence":
- The conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property […];
- The concealment or disguise of the true nature, source, location […], rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;
- The acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.
- Article 4 extends criminal liability to accomplices of those committing money laundering offense(s) by stating that "aiding and abetting, inciting and attempting an offence described in Article 3(1) … is punishable as a criminal offence."
- Article 5 demonstrates the EU's commitment to stricter AML enforcement against individual perpetrators. Article 5 calls for substantial penalties for individuals (natural persons) who are the actual perpetrators of the money laundering offense. Member States should ensure that individuals are punishable by a maximum imprisonment term of at least four years, and, where necessary, that individuals who have committed money laundering offense are "subject to additional sanctions or measures" (e.g., fines).
- Article 7 extends criminal liability for money laundering to "legal persons," or companies or corporations or other types of organizations doing business in the EU. These entities will face criminal liability for money laundering or, importantly, failure to prevent money laundering (Article 7(2)). Article 8 then provides samples of "proportionate and dissuasive sanctions," including criminal and non-criminal fines, as well as other sanctions, including exclusion of public funding and disqualification from commercial activities, among others.
- The Directive also promotes strengthening the cooperation among the relevant authorities of the EU member states in the prosecution of money laundering offenses. It does so by clarifying jurisdictional issues and factors that should be considered in determining which Member State should prosecute the offense. For example, Article 10, requires Member States to share information and cooperate if a money laundering offense has been committed within the jurisdiction of more than one EU Member State.
6AMLD was published on October 23, 2018 and EU Member States have until December 3, 2020 to transpose it into their national laws. Similar to 5AMLD, 6AMLD will likely be a "minimum harmonisation directive," thereby setting out minimum requirements and allowing the EU Member States to adopt at their respective national levels more stringent measures that go beyond it.
Danske Bank Scandal Update
There have been a few noteworthy developments in the Danske Bank money laundering scandal this year.
- Estonian Investigation Expands. In January 2020, the Estonian Prosecutor's office confirmed that it had expanded its investigation of Danske Bank's money laundering activities from two cases into over 10 cases related to suspect transactions with a value of approximately $2 billion. Previously, the prosecutors were investigating monetary transactions involving approximately $300 million.
- Investor Lawsuits Mount. 155 institutional investors filed a complaint in February 2020 against Danske Bank's former CEO Thomas Borgen seeking damages of DKK 2.6 billion (approximately $386 million). The lawsuit alleges that investors were misled at least since 2014. Borgen was the CEO of Danske Bank from 2013 until his resignation in 2018. In May 2019, Borgen was charged by Danish prosecutors for his involvement in Danske Bank's money laundering activities. This lawsuit comes on the heel of a suit filed in Denmark against Danske Bank on behalf of 60 international investors in December 2019 and two other lawsuits filed in the U.S.
Potential New U.S. Investigation of Swedbank over Sanctions Violations
In November 2019, Swedish TV network SVT reported that OFAC was investigating Swedbank AB (Swedbank), the Stockholm, Sweden-based Nordic-Baltic banking group, over links to Kalashnikov Concern JSC, the largest Russian developer and manufacturer of automatic assault and sniper weapons, and a Florida entity, both of which had been blacklisted by OFAC in July 2014.
Four months later, on March 11, 2020, Swedbank announced that it was reporting to OFAC that an internal investigation led by Clifford Chance had found 586 transactions amounting to almost $5 million that "constitute[d] potential OFAC violations" of U.S. sanctions on Russia and Ukraine. According to the announcement, Clifford Chance, which subsequently published its "Report of Investigation on Swedbank AB" on March 23, 2020, had examined "all the USD-denominated transactions" from the bank's subsidiaries in Estonia, Latvia, and Lithuania "processed through the U.S. financial system" during a five-year period (March 2014-March 2019). Clifford Chance identified that 95 percent of the transactions at issue were processed in 2015-2016, and that 508 transactions related to the operation of a vessel owned by an entity in Crimea, which has been subject to U.S. economic sanctions since 2014.
Swedbank said that it had addressed the shortcomings of its money laundering program, with 152 compliance initiatives at the end of January 2020, including enhancing Know Your Customer (KYC) procedures, transaction monitoring, and internal controls. Swedbank further said that "it [was] now a matter for the U.S. authority to decide how to proceed with the case, and potential consequences. The bank will cooperate fully with OFAC to resolve the matter." This potential new investigation by U.S. authorities into Swedbank's AML practices adds to the already ongoing investigations of the bank in the U.S., Sweden, and Estonia. As we reported in our previous edition of Money Laundering Enforcement Trends, Swedbank is facing scrutiny over allegations of money laundering in connection with more than $4 billion in transactions with Danske Bank's Estonian branch between 2007 and 2015. We will continue to follow up this development in the coming months.
The U.K. is referred to as "a hub for corrupt wealth from around the world" in the Transparency International U.K. "At Your Service" October 2019 report. The country has taken steps to combat money laundering and has signaled an emphasis on this going forward.
Unexplained Wealth Orders
In an effort to combat money laundering, in 2017, the U.K. introduced the Criminal Finances Act 2017, which amended the Proceeds of Crime Act 2002. The Criminal Finances Act 2017 includes expanded provisions for the U.K. government to confiscate funds, including terrorist property, and the proceeds of tax evasion. Among the tools in the Criminal Finances Act 2017 is the Unexplained Wealth Order (UWO).
UWOs, issued by the High Court, allow the U.K. government agencies to require individuals to explain how their obtained certain property. UWOs may be sought for assets exceeding £50,000 in value if there are grounds to believe that a person's income was insufficient to obtain them or that the person was involved in criminal activity. A UWO requires an alleged property owner to provide details on the lawfulness of his/her property ownership and the source of funds with which such assets were obtained.
Since 2018, U.K. government agencies have obtained several UWOs. One of these UWOs was directed against Zamira Hajiyeva, a wife of a jailed former chairman of the International Bank of Azerbaijan. In February 2020, Hajiyeva lost her UWO appeal and is now required to provide a detailed account of the funds used to purchase her assets. Other UWOs were directed at three properties owned by the daughter (Dariga Nazarbayeva) and grandson (Nurali Aliyev) of the former president of Kazakhstan, Nursultan Nazarbayev. The National Crime Agency alleged that the properties were obtained as a means to launder funds of Rakhat Aliyev, the ex-husband of Nazarbayeva and a former government official, including as chief of Kazakhstan's tax police. In April 2020, Nazarbayeva and Aliyev succeeded in challenging the three UWOs against them when the High Court ruled that there was not enough of a connection between Rakhat Aliyev and the properties. The National Crime Agency has indicated it plans to appeal.
New Levy to Boost AML Efforts
In March 2020, the U.K. government announced in its 2020 budget that it intends to introduce a new levy on entities subject to AML regulations "to help fund new government action to tackle money laundering and ensure delivery of the reforms committed to in the Economic Crime Plan." It is anticipated that this levy will be implemented by 2022-2023.
*Former Miller & Chevalier attorney
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